For everyone - here is the Frack Free Illinois list of recommendations, based on experts in the field of induced seismicity, sent to JCAR/IDNR, about avoiding and mitigating induced seismicity. This is the bottom line list that did not make it into the rules with yesterdays vote: A) All of these rules below would apply to both the shale oil and gas production wells and Class ll disposal wells, or much better defined; horizontal drilling with fracturing operations for oil and natural gas exploration, vertical wells for oil and natural gas that are fractured under high pressure, and Class ll disposal wells. B) A Seismic Active Zone Evaluation fee should be attached to any well permit within 3 miles of the Active Earthquake Zones of the Wabash Valley, New Madrid and Cottage Grove. This would pay for the ILGS to map out and test faulted areas fully - as delineated in the below rules, before approving any permits - this fee could also be used to pay the “Team” in rule C.- It must be set very high because some of it will go to paying for equipment and staff to fully evaluate the earthquake areas, but the bulk of it could be put into a state fund for paying for any law suits, road damage, property damage, pollution mitigation, etc that will be necessary if the fracking industry messes up, or skirts the rules! C) An Active Earthquake Zone Evaluation Team could be made up of scientific specialists, (independent contractors), who would make the final recommendation about whether a well permit should be allowed, which wells to be monitored more heavily, slowed, and/or stopped. This team could be made up of independent, university-based seismologists and geologists from around the country, who are actually studying induced seismicity - Frack Free Illinois could bring forth a list of names to be contacted. They could review the permits, the testing and seismic reports, and give consultations - we need to have highly trained eyes on these IL active seismic areas. The reports could be made public on the IDNR website within 2 days of receiving them. An “Active Earthquake Zone Evaluation Team” assisting the ILGS and the IDNR in their decisions for the active earthquake zones is a necessity, as already mentioned consisting of independent, university-based seismologists and geologists who are actively studying the issue of induced seismicity - it is a sub-specialty in the field. Mistakes made in the active earthquake zones would be devastating for our Southern and Central Illinois residents. D) One seismic monitor must be placed on every well, (horizontal fracturing wells, vertical wells fractured under high pressure, and Class ll disposal wells - no exceptions - with real time data sent into the IDNR and for the public to view. All seismic monitoring required could have real time data fed to the IDNR, and up on the website - the data must be made public immediately to insure that the fracking industry not turn off any monitors. As per Prof. Jacob: The continuous data stream of the seismic recordings must be accessible to the public on-line in graphical, and to regulatory agencies in digital form. The data in conjunction with DAILY (not monthly !!) pressure and flow data from said well can then be used by regulators to manage any potential seismic hazards and risks associated with the disposal well operation, including limits to maximum operation pressure, maximum flow rates; or - if found necessary -- temporary or permanent shut down of well operations. E) Green light = ONE earthquake less than magnitude 1.0 within 15 miles from a well. Yellow light = ONE magnitude 1 to 1.9 within 15 miles from a well (This would cause the 2-3-4 more seismic monitors to be placed within 5 miles of the well in question). We must have more monitoring when the earthquakes start happening - you are dealing with active earthquake zones and the National Seismic Monitoring System is NOT reliable throughout Southern IL - it only can pick up reliably 2.5 level earthquakes - that is not good enough. Red light = ONE magnitude 2 or larger 15 miles from a well (This would stop a well.) F) These rules for seismicity adopted in Ohio should be included - and also applied to all the wells listed in A: Ohio will seek the following reforms to its Class II deep injection well program: 1) Requires a review of existing geologic data for known faulted areas within the state and avoid the locating of new Class II disposal wells within these areas; 2) Requires of a complete suite of geophysical logs (including, at a minimum, gamma ray, compensated density-neutron, and resistivity logs) to be run on newly drilled Class II disposal wells. A copy of the completed log, with analytical interpretation will be submitted to ODNR; 3) Evaluates the potential for conducting seismic surveys; 4) Requires operators to plug back with cement, prior to injection, any well drilled in Precambrian basement rock for testing purposes. 5) Requires the submission, at time of permit application, of any information available concerning the existence of known geological faults within a specified distance of the proposed well location, and submission of a plan for monitoring any seismic activity that may occur; 6) Requires a measurement or calculation of original downhole reservoir pressure prior to initial injection; 7) Requires conducting a step-rate injection test to establish formation parting pressure and injection rates; 8) Requires the installation of a continuous pressure monitoring system, with results being electronically available to ODNR for review; 9) Requires the installation of an automatic shut-off system set to operate if the fluid injection pressure exceeds a maximum pressure to be set by ODNR; 10) Requires the installation of an electronic data recording system for purposes of tracking all fluids brought by a brine transporter for injection In March 2014 Ohio added: 11) New permits issued by ODNR for horizontal drilling within 3 miles of a known fault or area of seismic activity greater than a 2.0 magnitude would require companies to install sensitive seismic monitors. If those monitors detect a seismic event in excess of 1.0 magnitude, activities would pause while the cause is investigated. If the investigation reveals a probable connection to the hydraulic fracturing process, all well completion operations will be suspended. ODNR will develop new criteria and permit conditions for new applications in light of this change in policy. The department will also review previously issued permits that have not been drilled. Plus recommendations from experts, Prof. Beiersdorfer/Prof. Jacob: F) Requiring a sonic log in addition to the required gamma ray, compensated density-neutron, and resistivity logs. The sonic log can identify faults transected by the bore hole, the others can’t. This is important if the well drills through a fault plane. This was very relevant to the Youngstown injection well because the borehole penetrated about 200 feet into the basement rock and actually penetrated a fault. Normally, basement faults cannot be detected by any logs in the wells limited to the sedimentary layers. G) Monitoring - we can NOT rely on the unreliable National Seismic Monitoring System, it can not pick up earthquakes below a 2.5 reliably throughout the active earthquake zones of Southern IL - so it is insufficient! (This rule applies to ALL Class ll disposal wells, within a fault zone or without!) Supporting statements: Prof. Beiersdorfer: Therefore a minimum recommendation is the installation of at least one initial seismometer near every well targeted for fracking or waste disposal should be required. Prof. Jacob: It should be MANDATORY for every Class II waste disposal well that is actively used or about newly to be used to have at least one seismometer within (about) 5 miles of the well head installed and maintain it in reliable continuously operating condition. Once the seismometer detects seismicity with magnitudes of M = 1.5 or larger, at distances of less than 10 miles (that is with S-P wave arrival times of about 2 seconds or less) as measured from any portion of the well at or below ground, then within one month of such detection and array of at least 4 seismometers at distances out to 15 miles surrounding the well shall be installed. This number of seismometers (with a common time base within 1/100 of a second or better) is necessary to reliably locate the events and allows one instrument to temporarily fail and still obtain locatable hypocenter data of the seismic events. Prof. Beiersdorfer: In Ohio activities will pause at a Magnitude 1.0 event. After England’s fracking-induced earthquakes, the cut-off was set at Magnitude 0.5. The seismic magnitude cut-offs in the Illinois traffic light approach (Green 4) appear too high and are not restrictive enough to provide an appropriate level of public safety. For example, the observed seismicity due to fracking in the Horn River Basin of British Columbia, Canada were from Magnitudes 2.2 and 3.8 (British Columbia Oil and Gas Commission, 2012) These quakes were strong enough to deform the well casings in the lateral portions of nearby wells. This would fall in the Illinois Yellow zone, which requires nothing mandatory until three such events, after which there would be a consultation. The Northstar 1 well in Youngstown was shut down on December 30, 2011 and was followed by a Magnitude 4.0 earthquake the next day, that caused damage to peoples’ homes. In his report, Dr. Kim of Columbia University concluded “that continued injection of fluid at Northstar 1 well could have triggered potentially large and damaging earthquakes.” Prof. Jacob: I would go with green as long as there is no event of M=1 and/or larger within 15 miles of the well. I would go to yellow with at least one M=1 or larger within said distance I would go to red if there is one or more M=2 or larger within said distance. Another most important aspect is, that once seismic monitoring is established the data must be openly available to the public so they can verify instantly should they feel any seismicity, and of course must be available to the Illinois state agency overseeing the well activity. The technology to post real-time data on the web is readily and cheaply available and should be accessible via a website. Below is a copy of the Frack Free Illinois suggestions sent to JCAR and the IDNR, at the end of Sept, 2014, with further notes in Italicized Bold based on the recommendations from the experts to date: Section 240.796 Operating and Reporting Requirements, Hydraulic Fracturing Operations, Seismicity dnr.illinois.gov/ OilandGas/Documents/Final% 20Rules%2062-240.pdf a) Applicability b) Definitions Induced Seismicity means an earthquake event that is felt, recorded by the national seismic network, and attributable to a Class II UIC well used for disposal of flowback and produced fluid from high volume horizontal hydraulic fracturing operations. (Section 1-96(a) of the Hydraulic Fracturing Regulatory Act) Comment: This definition describes the need for earthquakes to be felt, (anywhere from 2-4 in magnitude). They also must be recorded by the national seismic network – but remember there is the lack of adequate monitoring in Southern Illinois. And no description of exactly how they are going to attribute a specific earthquake to a specific well. This definition is in HFRA but the IDNR could add their own definition to the rules such as Seismic Activity of Concern which would mean seismic events picked up by any seismic monitoring, not necessarily having to be felt, and tied to any oil and gas related exploration, extraction or disposal activity. c) Class II UIC Well Operations When a well is suspected of triggering induced seismic activity, the permittee shall consult with the Department and ISGS to develop a plan for seismic monitoring, including the possibility of installing monitoring stations in the vicinity of the well and reduction in rate or pressures of fluid injected. Comment: We object to requiring increase monitoring only when the earthquakes rise to the level of a 3-4 in strength, and only if it is picked up by the sparse monitoring stations in IL. It is irresponsible and reckless to wait until these triggers to discuss what kind of added monitoring will be required! Additional seismic monitoring in Southern Illinois should have been in the rules in the first place. We know from the experts that ALL horizontal wells, vertical wells fractured under high pressure, and disposal wells throughout Illinois should be required to have at least 1 seismic monitor with real time data being transmitted to the IDNR and up on their website in real time. To slow an injection well – It will take 3 earthquakes of 2.0 - 4.0 We know now this cut off should be at a level of one earthquake of magnitude 1 and that this should call for the addition of 4 other seismic monitors within at least 5 miles immediately. Cessation of wells: - 3 earthquakes of 2.0 – 4.0, and a notice of violation - Any number of earthquakes of 2.0 – 4.0, and one 4.5 (Red) but there must be property damage - 5 earthquakes of 2.0 – 4.0 We know now that these cutoffs are recklessly high. Red Lights: - An earthquake of over 4.0 and if well is 6 miles form the epicenter Comment: These cutoffs are reckless in the active earthquake zones, if even one level 4 earthquake is induced that well should be shut down, even 1 of them in the active earthquake zones is a very bad sign. If the numbers of level 2 - 3 earthquakes starts to increase, (like two in a row), then immediately that well, if in the active earthquake zone, should be shut down. Remember just slowing a well down, or even shutting it down, does not necessarily stop the earthquakes, there have been Class ll wells in Ohio that were stopped completely and the induced seismicity continued for over 15 years! We know now that this cutoff is recklessly high.
Posted on: Fri, 07 Nov 2014 18:53:45 +0000
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